Health Canada's CCCR reference manual for sections 4 and 5 is available at: [http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-4-article_e.html CCCR Reference Manual, Sections 4 and 5]. One of the important points they note is as follows:

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"A product may fall within more than one hazard category, based on its inherent hazards. For example, a toxic product packaged in an aerosol container would fall under both the toxic and pressurized container categories. If a product is classified in more than one sub-category within a hazard category, the most hazardous sub-category is used. For flammable products, the most hazardous sub-category is used as well as labelling for spontaneous combustion, if applicable"

A chemical product must be classified in the sub-category “toxic” if it has a viscosity of 14 mm2/s or less at 40°C and 10% or more of the product is composed of hazardous ingredients that pose an aspiration hazard, including, in particular, any of the following substances:

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(a) an n-primary alcohol with a composition of at least 3 carbon atoms but not more than 13;

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(b) an isobutyl alcohol;

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(c) a terpene alcohol;

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(d) a ketone with a composition of at least 3 carbon atoms but not more than 13;

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(e) a hydrocarbon with a composition of at least 3 carbon atoms but not more than 13; or

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(f) a substance that has been determined to be an aspiration hazard based on its viscosity, surface tension and water solubility through the application of generally accepted standards of good scientific practices.

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==CCCR Reference Manual - Sections 33 and 34==

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Health Canada's CCCR reference manual for sections 33 and 34 is available at: [http://www.hc-sc.gc.ca/cps-spc/pubs/indust/cccr-2001-rpccc/ref_man/sec-33-article_e.html CCCR Reference Manual, Sections 33 and 34]. One of the important points they note is as follows:

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"The classification criteria in subsection 34(1) assume that the other ingredients in the product are benign. However, if a product contains ingredients in addition to the substance of special concern that would make the product more hazardous, then the product must be classified into the higher sub-category (see subsection 4(3)). This means that the product will at least be classified according to subsection 34(1) and may be classified into a higher subcategory if other hazardous ingredients are present."

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==CCCR Technical Amendments - Sections 33 and 34==

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There are a number of references to section 34 in the [http://www.hc-sc.gc.ca/cps-spc/legislation/acts-lois/techni_e.html Proposed Technical Amendments to the Consumer Chemicals and Containers Regulations, 2001]. They are as follows:

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1. A chemical product that contains hydrocyanic acid or its salts, such as sodium cyanide or potassium cyanide, is classified as "very toxic" and is prohibited from consumer sale. These substances have been prohibited from consumer products under the Hazardous Products Act since 1988, and the prohibition was incorporated into the CCCR-2001. However, the Regulations are not consistent between English and French. The French wording correctly reads: "acide cyanhydrique ou ses sels"; the equivalent wording in English would be: "hydrocyanic acid or its salts".

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The CCCR-2001 will be amended to clarify the English text in subsection 34(1).

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Proposed Text:

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The portion of item 5 of the table to subsection 34(1) of the English version of the Regulations in column 1 is replaced by the following: Hydrocyanic acid or its salts

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2. The table to subsection 34(1) contains a list of substances which pose specific hazards to human health, thus requiring special classification. At present, the table to subsection 34(1) does not contain any information pertaining to the 'route of exposure' through which these substances pose a hazard. This will be addressed by adding a new column, "Column 4", to this table called "Route of exposure", which will permit manufacturers/importers to properly label their products for the dangers inherent to these chemical ingredients.

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3. The units for the LC50 criteria for gases and vapours should be mL/m3, not mg/m3. The toxicity limits that were developed in collaboration with all stakeholders were harmonized with Canadian and other international systems, in order to avoid redundant toxicity evaluations. The recommended limits were expressed in the units of ppm by volume. In the drafting of the CCCR-2001, it was intended to express the units in clear and unambiguous terms. However, the units were inadvertently printed as mg/m3 rather than mL/m3. As a result, the values are no longer harmonized with other systems and the criteria limits do not correspond to the stakeholder recommendations.

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The difference in units is related to the molecular weight of the substance relative to the molar volume of air. This means that higher molecular weight gases and vapours, such as toluene and xylene, would be excluded from classification when they were intended to be captured, whereas those with a lower molecular weight, such as ammonia, would be inappropriately classified into a higher sub-category.

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The amendment would change all references from mg/m3 to mL/m3 in the tables to subsections 1(4) and 34(4).

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==CCCR Technical Amendments - Sections 4 and 5==

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There are no references to section 4 or section 5 in the [http://www.hc-sc.gc.ca/cps-spc/legislation/acts-lois/techni_e.html Proposed Technical Amendments to the Consumer Chemicals and Containers Regulations, 2001]